Wolfe Mediation Services

Agreement to Mediate

This is an agreement among the undersigned (“the Parties”) and William Wolfe of Wolfe Mediation Services (“the Mediator”), to enter into mediation with the goal of resolving the disputes set out in Jones v. Smith, Ontario Superior Court of Justice File No. CV-0000-0001.

The Parties and the Mediator agree as follows:

1. Mediation is a confidential process and all parties have agreed to attend in good

faith to settle the disputes in the within litigation. The parties hereto agree to keep

all information and documentation exchanged in the mediation in strict

confidence, with or without a resolution of the litigation.

2. The Parties or their representatives shall attend the mediation with authority to

settle the matters in dispute.

3. The Parties agree that the Mediator shall not be compelled to testify in this or any

other proceeding, nor shall any notes, materials or reports be compelled to be

produced.

4. Unless authorized by the Parties, the Mediator shall not disclose confidential

information given to him by a party to any other party.

5. Any non-party attending mediation on consent of all parties, shall sign the

mediation agreement.

6. The Mediator does not provide legal advice and does not represent any of the

parties to the mediation agreement.

7. The minimum charge for a ½ day two party mediation is $2,800.00 +

HST/disbursements. The minimum charge for a full day mediation is $4,500. +

HST/Disbursements. A charge of $250 will be added for each additional party.

8. There are no cancellation fees, however non-refundable disbursement expenses

(i.e. facility rental) will be charged.

9. The Parties have agreed to utilize remote technology (Zoom) for the purpose of

mediation which the Mediator will facilitate, unless agreed otherwise.